A vehicle door can include a check structure that assists in retaining the door in one or more open positions after the door is moved from a closed position to an open position. Typically, the check structure includes a movement restricting mechanism that applies a force on the door to keep the door in one or more predetermined positions when opened. However, such check structures are not usually effective in all circumstances, such as when the vehicle is parked on a hill where the force of gravity can sometimes be sufficient to overcome the force of the check structure, thereby urging the door back to the closed position.